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Under the agreement, “FORBA has agreed to enter into an expansive five-year Corporate Integrity Agreement with the Office of the Inspector General of the Department of Health and Human Services. The agreement provides for procedures and reviews to be put in place to avoid and promptly detect conduct similar to that which gave rise to this matter.” Investigations into individual dentists continue with the company's cooperation.
..."In this case, FORBA put greed and profits before the well-being of children," said Timothy J. Heaphy, U.S. Attorney for the Western District of Virginia. "It endangered the health and safety of innocent children and defrauded the taxpayer of millions of dollars. Today’s settlement addresses these egregious acts and sends a clear message that Medicaid fraud will be expeditiously addressed by this Department."
On November 14, 2008 FORBA Holdings, LLC brought a lawsuit against one its biggest critics, Debbie Hagan, who runs a blog devoted to exposing the abuses of Small Smiles and other dental mills, alleging copyright infringement. The suit was dismissed on April 16, 2009 at FORBA's request.
In January 2010, the US Justice Department settled False Claims Act allegations against FORBA Holdings, LLC. Under the settlement, FORBA will pay $24 million plus interest to the US and several states. The investigation was spurred by three qui tam lawsuits filed by former employees in Maryland, Virginia and South Carolina in late 2007 and early 2008. The US Justice Department found that FORBA was liable for:
In January 2010, it gained national attention when Small Smiles' parent organization, Forba Holdings LLC, settled False Claims Act allegations with the United States Department of Justice. As of January 1, 2011 FORBA Holdings, LLC changed its name to Church Street Health Management (CSHM).

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